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Hinton v. Alabama, 571 U.S. 263

Case (cite)
Hinton v. Alabama, 571 U.S. 263
Year
2014
State
Alabama
Type of proceeding
Appellate
Type of claim
Ineffective assistance of counsel
Expert evidence ruling reversing or affirming on appeal:
Excluded
What was the ruling?
Error to Exclude; Remand
Type of evidence at issue:
Firearms identification
Defense or Prosecution Expert
Defense
Name of expert(s) who were the subject of the ruling
N/A
Summary of reasons for ruling
The issue was whether trial counsel was ineffective. Trial counsel’s failure to request additional funding in order to replace an expert he knew to be inadequate because he mistakenly believed that he had received all he could get under Ala. Code § 15-12-21(d) constituted deficient performance. Specifically, trial counsel knew he needed additional funding to present an adequate defense, yet he failed to make even the cursory investigation of the state statute providing for defense funding for indigent defendants that would have revealed to him that he could have received reimbursement not just for $1,000, but for any expenses reasonably incurred. In the instant case, the inadequate assistance of counsel was the inexcusable mistake of law, i.e., the unreasonable failure to understand the resources that state law made available to him, that caused counsel to employ an expert that he himself deemed inadequate. As for the prejudice prong of the Strickland analysis, a remand was necessary because no court had yet applied the proper inquiry to the facts of the case.
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
Strickland v. Washington
Did lower court hold a hearing
Y
Names of prosecution expert(s) two testified at hearing
N/A
Names of defense expert(s) who testified at hearing (or None).
N/A
Discussion of 2009 NAS Report (NAS2009) or PCAST report (PCAST)
N
Discussion of error rates / reliability
N
Frye Ruling
N
Limiting testimony ruling
N
Language imposed by court to limit testimony
N/A
Ruling based in prior precedent / judicial notice
N
Daubert ruling emphasizing – which factors – (list 1-5)
N/
Ruling on qualifications of expert
N
Ruling on 702(a) – the expert will help / assist the jury
N
Ruling on 702(b) – the testimony is based on sufficient facts or data
N
Ruling on 702(c) – the testimony is the product of reliable principles and methods
N
Ruling on 702(d) – reliable application of principles and methods to the facts of the case
N

Notes

Note: there are several lower court rulings on the standard applied to expert testimony on firearms identification.